transzferármegállapítások

Transzferár megállapítás refers to the process of determining the appropriate price for goods or services exchanged between related entities within a multinational corporation, such as different subsidiaries or branches. This practice is crucial for tax authorities worldwide, as it aims to prevent companies from manipulating prices to shift profits to lower-tax jurisdictions. The core principle of transzferár megállapítás is the arm's length principle, which dictates that the price should be the same as if the transaction occurred between independent parties in comparable circumstances.

Tax authorities scrutinize these intercompany transactions to ensure they reflect fair market value. If prices are found to be non-compliant, tax authorities can adjust the declared profits and impose additional taxes, penalties, and interest. Companies are required to document their transzferár megállapítás methodologies and justifications to demonstrate compliance. Common methods include comparable uncontrolled price (CUP), resale price method (RPM), cost plus method, transactional net margin method (TNMM), and profit split method. The choice of method depends on the nature of the transaction and the availability of comparable data. Effective transzferár megállapítás requires a thorough understanding of the business, industry, and relevant tax regulations.